Sounds like it. Non-US person but also not an EU citizen (or EEA or Swiss or even British) and... apart from the negative rate (which is true), I honestly never encountered unceremoniously closing accounts while Americans complain it all the time (and they usually know it's because of FATCA - they also wish it was gone but they don't make the decisions: Americans at home are the ones deciding that they really want to see everone's account in the name of tax evasion).